I am Valerie Jablow, a DCPS parent. I am sending you all this via email because it is the only way I can get timely feedback to you on OSSE’s response to your recommendations on ESSA. I urge you to vote NO on OSSE’s ESSA proposal.

Yesterday afternoon, I found out about OSSE’s response to public comment on its ESSA draft proposal.

I didn’t get to read that response until this morning, while eating breakfast and trying to get my kids out the door.

Then I read that OSSE would promulgate a new draft plan by the end of today, which I have not yet seen.

How do you keep up?

Perhaps more importantly, how does any parent, teacher, or administrator keep up?

Back in November, I and other parents of public school students in DC testified before you about the horrible effect of a test-heavy emphasis in accountability on students and schools in DC.

In February, when the superintendent of OSSE and her chief of staff held a public meeting in Ward 6 on ESSA, they touted the feedback they had already received in 50 meetings with 100 different groups. And they repeatedly said that teachers, principals, and parents wanted the heavy-test emphasis of its draft proposal.

Jaws dropped in the room that night. Who were those people who wanted testing to dominate accountability? Certainly not anyone we knew in our schools!

Thus, several weeks ago I made a FOIA request of OSSE, for a list of meetings, participants, and feedback received in all its meetings on ESSA from such groups and individuals from January 1, 2016 through the end of February 2017.

Right now, the best evidence we have for such feedback is OSSE’s response document from yesterday—in which “many” and “some” commenters are said to have said something, all of which is not necessarily reflected in what OSSE is now proposing to do with ESSA!

Thus, I hope that my FOIA request will allow me and others to find out what the Chesapeake Bay Foundation had to say about ESSA in DC public schools—as well as the other organizations whose staff met with OSSE on ESSA implementation for more than a YEAR, while all of us DC citizens (who, unlike the Chesapeake Bay Foundation, actually have children and/or taxes in this game) had only 33 days to comment on the proposal. (Which is three days more than the federal minimum of 30 days for public comment–and a few days more than the DCPS chancellor got.)

Perhaps the most radical thing in OSSE’s draft calls for schools being taken over by other operators when their test scores do not go up after 4 years (p. 59).

As you know, even with the changes it is proposing, OSSE is still placing a heavy emphasis on test scores and attendance. At the same time, there is nothing in OSSE’s accountability framework that penalizes schools whatsoever for high suspension and expulsion rates.

So what is to stop a school from suspending and expelling its way into higher attendance rates or higher test scores?

Nothing.

And where will those students go when they are expelled or encouraged to leave?

To their by right schools!

So what does OSSE’s proposal do to take this differential into account and its effect on the scores of receiving schools?

Nothing.

This is what you are voting for with OSSE’s policy here.

As you know, our city creates new charter schools whenever and wherever, without any regard for the effect on existing schools, neighborhoods, or unfilled seats.

As a result, DCPS is losing about 1% per year of “marketshare,” because growth in DC public school seats does not match growth of overall enrollments or of our student population. Just next week, for instance, the charter board will hear comments on proposals by two charter operators—KIPP DC and DC Prep—to create five new schools and 4000 new seats. The board will vote on those proposals in April. The board has also received applications for eight new charter schools beyond that, which it will vote on in May.

At the same time that the charter board is considering 13 (!) new schools, DC has more than 10,000 unfilled seats at existing public schools. (Data from 21st Century School Fund, using current audited enrollment numbers and MFP.)

So what will happen ten years from now, when these ESSA rules are up for re-assessment?

Absent any change from city leaders in our public school governance, DCPS will certainly be the smallest school system. This means more DCPS closures.

And absent any change in this OSSE policy, it means that some schools in DCPS will just become a place for kids off’ed from other schools, as those other schools chase better attendance and higher test scores—and thus create an even faster metric by which receiving DCPS schools will be taken over or closed altogether, because there is no accounting for this dynamic whatsoever in this policy or any city governance of our public schools.

This is what you are voting for with OSSE’s policy here.

One of the aims of OSSE’s ESSA policy is to provide a way to compare schools fairly and to have a common system of accountability between them. But this betrays a facile notion of how our schools actually work.

As you know, one school system in our city is bound to uphold a RIGHT to education. That is DCPS. The other system, charter schools, is not bound to uphold that RIGHT. That immediately differentiates the two sectors in a way that cannot be compared. It doesn’t mean one is better than the other—it simply means that they are different by design. Why wouldn’t you have a system of accountability that takes that difference into account instead of actively denying it even exists?

Moreover, there is nothing common between those two sectors in expulsion rules; suspension rules; facilities requirements; curricula; teacher training; and teacher retention rates—all of which are important not only to student achievement, but also in accountability to the public. OSSE’s proposal doesn’t acknowledge any of this.

In fact, OSSE has made some rather huge assumptions in its draft proposal, which distort true accountability.

To wit:

–That student satisfaction = school success = higher attendance rates. (See p. 5 of the response document.) What evidence is given to show attendance is 100% (or some other percentage) in the control of each school? What evidence is given to show that student satisfaction means the school is “successful” and that students will attend at higher rates? Indeed, what is “success” in this scheme if not mainly high test scores?

–That one of the purposes of the new rating system is to facilitate school choice by parents. This is perhaps the most grotesque distortion of ESSA possible. The point of school accountability is not to facilitate school choice, but to help students and to help schools help them. What assurance is here that parents and teachers will be able to use these test results and other criteria measured to help students learn better, except only in a punitive way, to avoid censure or takeover? Facilitating school choice should be the LAST thing that anyone is concerned about when it comes to helping our kids learn!

These assumptions and distortions are what you are voting for with OSSE’s policy here.

Finally, a note about compromise:

OSSE characterized its response yesterday to you and the public as a compromise.

But you, collectively, put together ten recommendations on OSSE’s draft proposal as a compromise before that—most of which have not even made it into OSSE’s response document.

So how much of a compromise was OSSE’s response yesterday—and for whom is it a compromise?

Here is a more concrete example:

OSSE’s rationale for not measuring high school growth is that different groups of high school students take different PARCC math tests and that it distorts scoring when those scores are combined.

OK. But right now, OSSE groups together middle school accelerated math test scores with regular math test scores and blithely spits out a number for both achievement and growth. That practice does indeed distort test scores—but OSSE has determined that’s OK with middle schools.

What sort of compromise is this?

I can attest that OSSE’s practice with those middle school scores has actively hurt my DCPS middle school, because a relatively large portion of its student body takes those accelerated math tests—whereas most other middle schools avoid those tests or have only a small fraction of their students take them.

So, instead of giving up on measuring high school growth or accurate middle school reporting, how about reporting data more responsibly (i.e., separate out results for accelerated tests)–or just using a different measure of math achievement than PARCC?

For all these reasons, I ask you to please not accept what OSSE is offering now. It is only a compromise of our ability to have rich, nuanced, and accurate assessments, which we desperately need and are not getting.

Your voting NO to OSSE’s proposal will give all of us time to make a policy of accountability that will reflect well on each school and every child. Thank you.